Privacy Policy

PRIVACY POLICY
(In Compliance with the Nigeria Data Protection Act (NDPA) 2023)
This Privacy Policy explains how Hostel Management (“Management,” “we,” “our,” or “us”) collects, processes, stores, and protects personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023 and other applicable laws of the Federal Republic of Nigeria.
By registering for accommodation, making payment, submitting personal information, or occupying the hostel premises, you consent to the processing of your personal data in accordance with this Policy.
________________________________________
1. Data Controller
Hostel Management acts as the Data Controller responsible for determining the purposes and means of processing personal data collected from students and parents/guardians.
For data-related inquiries, complaints, or requests, contact:
kinqihomes@gmail.com

________________________________________
2. Categories of Personal Data Collected
We may collect and process the following categories of personal data:
a. Identification Information
• Full name
• Date of birth
• Gender
• Passport photograph
• National ID or School ID
b. Contact Information
• Phone number
• Email address
• Residential/home address
• Parent/Guardian contact details
c. Academic Information
• Institution name
• Matriculation/Registration number
d. Financial Information
• Payment records
• Transaction references
e. Security Data
• CCTV footage in common areas
• Visitor logs
We do not intentionally collect sensitive personal data unless required for safety or legal compliance.
________________________________________
3. Lawful Basis for Processing
In accordance with the NDPA 2023, we process personal data based on:
1. Consent – Where you voluntarily provide your information during registration.
2. Contractual Necessity – To provide accommodation services.
3. Legal Obligation – To comply with Nigerian laws and lawful requests from authorities.
4. Legitimate Interest – For security, safety, and proper hostel administration.
________________________________________
4. Purpose of Data Processing
Personal data is processed for:
• Hostel registration and room allocation
• Communication with students and parents/guardians
• Safety, security, and CCTV monitoring
• Emergency response and welfare management
• Financial record-keeping and auditing
• Compliance with regulatory and legal obligations
We shall not process personal data for purposes incompatible with those listed above without obtaining additional consent.
________________________________________
5. Data Retention
Personal data shall be retained only for as long as necessary to:
• Fulfill the purpose for which it was collected
• Comply with legal or regulatory requirements
• Resolve disputes or enforce agreements
After the retention period, data will be securely deleted or anonymized.
________________________________________
6. Data Security Measures
In compliance with NDPA 2023, Management implements appropriate technical and organizational measures including:
• Restricted access to personal records
• Secure storage (physical and digital)
• Password-protected systems
• Confidential handling by authorized personnel only
________________________________________
7. Data Subject Rights
Under the NDPA 2023, students and parents/guardians (Data Subjects) have the right to:
1. Request access to personal data held about them
2. Request correction of inaccurate or incomplete data
3. Request erasure of data (where legally permissible)
4. Withdraw consent (where processing is based on consent)
5. Object to certain types of processing
6. Lodge complaints with the Nigeria Data Protection Commission (NDPC)
Requests must be submitted in writing to Management.
________________________________________
8. Data Sharing & Disclosure
We do not sell or rent personal data. However, personal data may be disclosed:
• To law enforcement agencies when legally required
• To regulatory authorities
• To educational institutions where necessary
• To parents/guardians in matters involving student welfare
All disclosures shall comply with NDPA requirements.
________________________________________
9. CCTV Surveillance
CCTV cameras may be installed in common areas strictly for security and safety purposes. Cameras are not installed in private areas such as bathrooms or toilets.
Footage is stored securely and accessed only when necessary for investigations or security review.
________________________________________
10. Cross-Border Data Transfer
Personal data shall not be transferred outside Nigeria unless adequate safeguards are in place in compliance with NDPA 2023.
________________________________________
11. Breach Notification
In the event of a data breach likely to result in risk to data subjects, Management shall:
• Notify the relevant regulatory authority as required by NDPA
• Inform affected individuals where necessary
________________________________________
12. Amendments
Management reserves the right to amend this Privacy Policy in compliance with evolving legal requirements. Continued occupancy or use of hostel services constitutes acceptance of any updates.
________________________________________
13. Governing Law
This Privacy Policy shall be governed and interpreted in accordance with the laws of the Federal Republic of Nigeria.
________________________________________
Declaration
By registering for accommodation or occupying the hostel premises, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data in accordance with the Nigeria Data Protection Act 2023.